- 19 - body size in its inventory computations subsequent to Richardson I. In the alternative, respondent determined that Investments made an unauthorized change in method of accounting when it changed the definition of its inventory units for its new car pool from body size to model line in taxable year 1981. Petitioner asserts that Investments did not make an unauthorized change in method of accounting in either instance. Section 446(e) provides that "a taxpayer who changes the method of accounting on the basis of which he regularly computes his income in keeping his books shall, before computing his taxable income under the new method, secure the consent of the Secretary."11 The Internal Revenue Code does not define the phrase “change in method of accounting”. However, the regulations under section 446(e) provide that a “change in the method of accounting includes a change in the overall plan of accounting for gross income or deductions or a change in the treatment of any material item used in such overall plan.” Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. Furthermore, with respect to inventories, the regulations provide: A change in an overall plan or system of identifying or valuing items in inventory is a change in method of accounting. Also a change in the treatment of any material item used in the overall plan for identifying or valuing items in inventory is a change in method of accounting. [Sec. 1.446-1(e)(2)(ii)(c), Income Tax Regs.] 11 Consent is requested by filing an application on Form 3115. Sec. 1.446-1(e)(3)(i), Income Tax Regs.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011